Caledonia Ash Land ill Caledonia, WI

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1 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT Caledonia Ash Land ill Caledonia, WI We Energies January 31, 2018

2 CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT JANUARY 31, 2018 PROJECT # Annual Groundwater Monitoring and Corrective Action Report Caledonia Ash Landfill Caledonia, Wisconsin Prepared for: WEC Business Services, LLC 333 W. Everett Street Milwaukee, WI KRISTEN L. THEESFELD Hydrogeologist GLENN R. LUKE, PE Managing Engineer OBG THERE S A WAY

3 CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT TABLE OF CONTENTS TABLE OF CONTENTS TABLES... ii FIGURES... ii ACRONYMS AND ABBREVIATIONS... iii 1 INTRODUCTION Overview Monitoring and Corrective Action Program Status KEY ACTIONS COMPLETED IN Summary Problems Encountered and Actions to Resolve Problems KEY ACTIVITIES PLANNED FOR Summary... 3 REFERENCES... 4 OBG JANUARY 31, 2018 FINAL I Caledonia Ash Landfill 2017 Annual Report FINAL docx

4 CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT TABLE OF CONTENTS TABLES Table 1 Table 2 FIGURES Figure 1 Caledonia Ash Landfill: Appendix III Analytical Results Caledonia Ash Landfill: Appendix IV Analytical Results Groundwater Sampling Well Location Map OBG JANUARY 31, 2018 FINAL II Caledonia Ash Landfill 2017 Annual Report FINAL docx

5 ACRONYMS AND ABBREVIATIONS CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT ACRONYMS AND ABBREVIATIONS CCR CFR mg/l OBG SSI STD Coal Combustion Residuals Code of Federal Regulations milligrams per liter O Brien & Gere Engineers, Inc. Statistically Significant Increase standard units OBG JANUARY 31, 2018 FINAL III Caledonia Ash Landfill 2017 Annual Report FINAL docx

6 CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT INTRODUCTION 1 INTRODUCTION 1.1 OVERVIEW This report has been prepared on behalf of We Energies by O Brien & Gere Engineers, Inc. (OBG), to provide the information required by Title 40 of the Code of Federal Regulations (40 CFR) Part (e) for the Caledonia Ash Landfill located in Caledonia, Wisconsin. In accordance with 40 CFR (e), the owner or operator of an existing coal combustion residual (CCR) unit must prepare an annual groundwater monitoring and corrective action report (Annual Report) for the preceding calendar year. The Annual Report must document the status of the groundwater monitoring and corrective action program for the CCR unit and summarize key actions completed, describe any problems encountered, discuss actions to resolve the problems, and project key activities for the upcoming year. At a minimum, the Annual Report must contain the following information, to the extent available: (1) A map, aerial image, or diagram showing the CCR unit and all background (or upgradient) and downgradient monitoring wells, to include the well identification numbers, that are part of the groundwater monitoring program for the CCR unit; (2) Identification of any monitoring wells that were installed or decommissioned during the preceding year, along with a narrative description of why those actions were taken; (3) In addition to all the monitoring data obtained under 40 CFR through , a summary including the number of groundwater samples that were collected for analysis for each background and downgradient well, the dates the samples were collected, and whether the sample was required by the detection monitoring or assessment monitoring programs; (4) A narrative discussion of any transition between monitoring programs (e.g., the date and circumstances for transitioning from detection monitoring to assessment monitoring in addition to identifying the constituent(s) detected at a statistically significant increase over background levels); and (5) Other information required to be included in the annual report as specified in 40 CFR through This report provides the required information for the Caledonia Ash Landfill for calendar year MONITORING AND CORRECTIVE ACTION PROGRAM STATUS The final three independent samples of the minimum eight required by 40 CFR (b) were collected and analyzed from each background and downgradient well before October 17, 2017, with the exception of W12D, W49, and W50 as further described in Section 2.2. The other five independent samples were collected and analyzed in 2015 and 2016 for all wells except W49 and W50. The collection of eight independent background samples was completed by October 17, The first semiannual monitoring sample for the Detection Monitoring Program for Appendix III parameters was collected on November 14-15, 2017 from each well; the analytical data was received on December 18, Determination of statistically significant increases (SSI) of Appendix III parameters over background concentrations will be completed within 90 days of completing the sample analysis, but not later than January 15, For calendar year 2017, corrective action and other information required to be included in the annual report as specified in 40CFR through is not applicable. OBG JANUARY 31, 2018 FINAL 1 OF 4 Caledonia Ash Landfill 2017 Annual Report FINAL docx

7 2 KEY ACTIONS COMPLETED IN SUMMARY CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT KEY ACTIONS COMPLETED IN 2017 Three groundwater sampling events were completed in 2017 as part of an effort initiated in 2015 to collect eight independent samples from background and downgradient monitoring wells in accordance with 40 CFR (b). Subsequent to collection of the eight independent samples, an additional sampling event was completed in November 2017 for parameters listed in Appendix III, 40 CFR Part 257, to supplement the background data set and as the first semi-annual monitoring sampling event for the Detection Monitoring Program. A map showing the groundwater monitoring system, including the CCR unit and all background (upgradient) and downgradient monitoring wells with well identification numbers, for the Caledonia Ash Landfill is presented in Figure 1. Samples were collected and analyzed in accordance with the Sampling and Analysis Plan (Natural Resource Technology, an OBG Company, 2017) prepared for the Caledonia Ash Landfill. All monitoring data obtained under 40 CFR through (as applicable) in 2017, as well as monitoring data for the previously collected five independent samples are presented in Tables 1 and 2. Sample collection dates in 2017 were February 8, April 15, August 21-22, and November Sample collection dates for previously collected five independent samples are identified in Tables 1 and 2. Statistical evaluation of analytical data from the eight independent samples required to be collected by October 17, 2017 and the first semi-annual detection monitoring event on November 14-15, 2017 was initiated and will be completed within 90 days of October 17, 2017 (January 15, 2018). Statistical evaluation of analytical data is being performed in accordance with the Statistical Analysis Plan, Caledonia Ash Landfill (Natural Resource Technology, an OBG Company, 2017). 2.2 PROBLEMS ENCOUNTERED AND ACTIONS TO RESOLVE PROBLEMS Groundwater samples were collected and analyzed in accordance with the Sampling and Analysis Plan, and all data was accepted. Based on observed fluctuations in groundwater flow direction since 2015, additional monitoring locations were necessary to adequately monitor groundwater downgradient of the Caledonia Ash Landfill. Also, during 2017 site access was improved in areas east-southeast of the landfill, allowing for installation of new groundwater monitoring well W50 closer to the CCR unit and in the same downgradient position as W12D, which had been part of the monitoring network. New groundwater monitoring wells W49 and W50 were installed from April 18, 2017 to April 19, 2017 and added to the monitoring network to provide additional downgradient groundwater monitoring coverage and groundwater elevation data. In 2017, monitoring well W12D was removed from the monitoring network and replaced by well W50, which provides downgradient coverage east-southeast of the landfill and is located adjacent to the CCR unit. Groundwater monitoring data obtained from well W12D prior to the installation of W50 and during the collection of the eight independent samples from background and downgradient monitoring wells is provided in Tables 1 and 2. Monitoring well locations are shown on Figure 1. OBG JANUARY 31, 2018 FINAL 2 OF 4 Caledonia Ash Landfill 2017 Annual Report FINAL docx

8 3 KEY ACTIVITIES PLANNED FOR SUMMARY The following key activities are planned for 2018: CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT KEY ACTIVITIES PLANNED FOR 2018 Continuation of the Detection Monitoring Program with semi-annual sampling scheduled for the 2 nd and 4 th quarters of Complete evaluation of analytical data from the downgradient wells, using both the eight samples required to be collected by October 17, 2017 and the first semi-annual detection monitoring sample taken in November 2017 to determine whether a SSI of Appendix III parameters over background concentrations has occurred. If an SSI is identified, potential alternate sources (i.e., a source other than the CCR unit caused the SSI or that that SSI resulted from error in sampling, analysis, statistical evaluation, or natural variation in groundwater quality) will be evaluated. If an alternate source is demonstrated to be the cause of the SSI, a written demonstration will be completed within 90 days of SSI detection and included in the annual groundwater monitoring and corrective action report for 2018.» If an alternate source(s) is not identified to be the cause of the SSI, the applicable requirements of 40 CFR through (e.g., assessment monitoring) will apply in 2018, including associated recordkeeping/notifications required by 40 CFR through OBG JANUARY 31, 2018 FINAL 3 OF 4 Caledonia Ash Landfill 2017 Annual Report FINAL docx

9 CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT REFERENCES REFERENCES Natural Resource Technology, an OBG Company, 2017, Sampling and Analysis Plan Revision 2, Caledonia Ash Landfill, Caledonia, Wisconsin, September 29, Natural Resource Technology, an OBG Company, 2017, Statistical Analysis Plan, Caledonia Ash Landfill, Caledonia, Wisconsin, October 17, OBG JANUARY 31, 2018 FINAL 4 OF 4 Caledonia Ash Landfill 2017 Annual Report FINAL docx

10 CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT Tables OBG THERE S A WAY

11 January 30, :06:14 AM Caledonia Table 1. Caledonia Ash Landfill: Appendix III Analytical Results Date Range: 11/11/2015 to 11/15/2017 Well Id Date Sampled Lab Id B, tot, mg/l Ca, tot, mg/l Cl, tot, mg/l F, tot, mg/l ph (field), STD SO4, tot, mg/l W08D 11/11/ /16/ /11/ /30/ /14/ /08/ /15/ /22/ /14/ W09D 11/11/ /16/ /11/ /30/ /14/ /08/ /15/ /22/ /14/ W10D 11/11/ /17/ /11/ /30/ /14/ /08/ /15/ /22/ /14/ W12D 11/11/ /16/ /11/ /30/ /14/ /08/ /15/ /22/ W46D 11/11/ MANAGES

12 January 30, :06:14 AM Caledonia Table 1. Caledonia Ash Landfill: Appendix III Analytical Results Date Range: 11/11/2015 to 11/15/2017 B, tot, mg/l Ca, tot, mg/l Cl, tot, mg/l F, tot, mg/l ph (field), STD SO4, tot, mg/l W46D 02/17/ /11/ /30/ /14/ /08/ < /16/ /21/ /14/ W48 11/11/ /16/ /11/ /30/ < /14/ < /08/ /15/ < /21/ < /15/ <1.000 W49 06/21/ /22/ /15/ W50 06/02/ /22/ /15/ MANAGES

13 January 30, :06:17 AM Caledonia Table 1. Caledonia Ash Landfill: Appendix III Analytical Results Date Range: 11/11/2015 to 11/15/2017 Well Id Date Sampled Lab Id TDS, mg/l W08D 11/11/ /16/ /11/ /30/ /14/ /08/ /15/ /22/ /14/ W09D 11/11/ /16/ /11/ /30/ /14/ /08/ /15/ /22/ /14/ W10D 11/11/ /17/ /11/ /30/ /14/ /08/ /15/ /22/ /14/ W12D 11/11/ /16/ /11/ /30/ /14/ /08/ /15/ /22/ W46D 11/11/ MANAGES

14 January 30, :06:17 AM Caledonia Table 1. Caledonia Ash Landfill: Appendix III Analytical Results Date Range: 11/11/2015 to 11/15/2017 TDS, mg/l W46D 02/17/ /11/ /30/ /14/ /08/ /16/ /21/ /14/ W48 11/11/ /16/ /11/ /30/ /14/ /08/ /15/ /21/ /15/ W49 06/21/ /22/ /15/ W50 06/02/ /22/ /15/ MANAGES

15 January 30, :19:17 AM Caledonia Table 2. Caledonia Ash Landfill: Appendix IV Analytical Results Date Range: 11/11/2015 to 10/17/2017 Well Id Date Sampled Lab Id As, tot, mg/l Ba, tot, mg/l Be, tot, mg/l Cd,tot, mg/l Co, tot, mg/l Cr, tot, mg/l W08D 11/11/ < < < < /16/ < < < < /11/ < < < < /30/ < < < < /14/ < < < < /08/ < < < < /15/ < < < < /22/ < < < < W09D 11/11/ < < < < /16/ < < < < /11/ < < < < /30/ < < < < /14/ < < < < /08/ < < < < /15/ < < < < /22/ < < < < W10D 11/11/ < < < /17/ < < < /11/ < < < < /30/ < < < < /14/ < < < < /08/ < < < < /15/ < < < < /22/ < < < < W12D 11/11/ < < < < /16/ < < < < /11/ < < < < /30/ < < < < /14/ < < < < /08/ < < < < < /15/ < < < < /22/ < < < < < W46D 11/11/ < < < < /17/ < < < < /11/ < < < < /30/ < < < < MANAGES

16 January 30, :19:17 AM Caledonia Table 2. Caledonia Ash Landfill: Appendix IV Analytical Results Date Range: 11/11/2015 to 10/17/2017 As, tot, mg/l Ba, tot, mg/l Be, tot, mg/l Cd,tot, mg/l Co, tot, mg/l Cr, tot, mg/l W46D 11/14/ < < < < /08/ < < < < /16/ < < < < /21/ < < < < W48 11/11/ < < < < /16/ < < < < /11/ < < < < /30/ < < < < /14/ < < < < /08/ < < < < /15/ < < < < /21/ < < < < W49 06/21/ < < /22/ < < < < W50 06/02/ < < < < /22/ < < < < MANAGES

17 January 30, :19:20 AM Caledonia Table 2. Caledonia Ash Landfill: Appendix IV Analytical Results Date Range: 11/11/2015 to 10/17/2017 Well Id Date Sampled Lab Id F, tot, mg/l Hg, tot, mg/l Li, tot, mg/l Mo, tot, mg/l Pb, tot, mg/l Sb, tot, mg/l W08D 11/11/ < < < /16/ < /11/ < /30/ < < < /14/ < < < /08/ < < /15/ < < < /22/ < < < W09D 11/11/ < < /16/ < /11/ < /30/ < /14/ < /08/ < < < /15/ < < /22/ < < < W10D 11/11/ < /17/ < /11/ < /30/ < < < /14/ < < < /08/ < /15/ < < /22/ < < < W12D 11/11/ < < /16/ < /11/ < < /30/ < < < /14/ < /08/ < < < /15/ < /22/ < < < W46D 11/11/ < < /17/ < /11/ < /30/ < MANAGES

18 January 30, :19:20 AM Caledonia Table 2. Caledonia Ash Landfill: Appendix IV Analytical Results Date Range: 11/11/2015 to 10/17/2017 F, tot, mg/l Hg, tot, mg/l Li, tot, mg/l Mo, tot, mg/l Pb, tot, mg/l Sb, tot, mg/l W46D 11/14/ < /08/ <0.500 < /16/ < < /21/ < < W48 11/11/ < < /16/ < < /11/ < < < < /30/ < < /14/ < < < < /08/ < < /15/ < < /21/ < < W49 06/21/ < /22/ < W50 06/02/ < /22/ < < < MANAGES

19 January 30, :19:22 AM Caledonia Table 2. Caledonia Ash Landfill: Appendix IV Analytical Results Date Range: 11/11/2015 to 10/17/2017 Well Id Date Sampled Lab Id Ra , PCi/L Se, tot, mg/l Tl, tot, mg/l W08D 11/11/ < /16/ /11/ < < /30/ < < /14/ < < /08/ < < /15/ < < /22/ < < W09D 11/11/ < < /16/ < < /11/ < < /30/ < /14/ < /08/ < < /15/ < < /22/ < < W10D 11/11/ < < /17/ < < /11/ < < /30/ < < /14/ < < /08/ < /15/ < < /22/ < < W12D 11/11/ < < /16/ < /11/ < < /30/ < < /14/ /08/ < < /15/ /22/ < < W46D 11/11/ < < /17/ < < /11/ < < /30/ < < MANAGES

20 January 30, :19:22 AM Caledonia Table 2. Caledonia Ash Landfill: Appendix IV Analytical Results Date Range: 11/11/2015 to 10/17/2017 Ra , PCi/L Se, tot, mg/l Tl, tot, mg/l W46D 11/14/ < < /08/ < < /16/ < < /21/ < < W48 11/11/ < /16/ < < /11/ < < /30/ /14/ < < /08/ < /15/ < < /21/ < W49 06/21/ /22/ W50 06/02/ /22/ < MANAGES

21 CALEDONIA ASH LANDFILL 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT Figures OBG THERE S A WAY

22 "D W49 D" W10D D" W46D W09D D" W50 "D D" W12D Y:\GIS\Projects\16\1660\MXD\2017agwmcar\Figure 1_GW Samp Well Loc_Caledonia.mxd Author: stolzsd; Date/Time: 1/29/2018, 5:09:08 PM "D "D "D "D D" CCR RULE BACKGROUND MONITORING WELL LOCATION CCR RULE DOWNGRADIENT MONITORING WELL LOCATION CCR RULE UPGRADIENT MONITORING WELL LOCATION FORMER CCR RULE MONITORING WELL LOCATION DRAWN BY/DATE: SDS 1/17/18 REVIEWED BY/DATE: GRL 1/17/18 APPROVED BY DATE: GRL 1/29/18 W48 D" W08D Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community GROUNDWATER SAMPLING WELL LOCATION MAP 2017 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT WE ENERGIES CALEDONIA ASH LANDFILL CALEDONIA, WISCONSIN ³ SCALE IN FEET PROJECT NO: FIGURE NO: 1

23 OBG THERE S A WAY